Matter of Batista-Hernandez,
21 I. & N. Dec. 955 (BIA July 15, 1997) (federal conviction
pursuant to 18 U.S.C. § 3 as accessory after the fact to a
drug-trafficking crime does not establish deportability as
a drug-trafficking aggravated felony under INA § 101(a)(43)(B),
8 U.S.C. § 1101(a)(43)(B), because accessory after the fact
is not listed as an inchoate offense (like attempt and conspiracy)
that Congress chose to consider an aggravated felony under
INA § 101(a)(43)(U), 8 U.S.C. 1101(a)(43)(U)).